SITE INFORMATION AND CORRESPONDENCE

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• • MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 G TO: Wendy L. Cohen FROM: Michael Higgins Senior Engineer Project E gineer DATE: 24 April 1990 SIGNATURE: � , SUBJECT: SUBCHAPTER 15 COMPLIANCE REVIEW, CLOSURE AND POST-CLOSURE PLANS FOR PITS 1 AND 7, UNIVERSITY OF CALIFORNIA, LAWRENCE L I VERMORE NATIONAL LABORATORY SITE 300; SAN JOAQUIN COUNTY -CASE #2677 Introduction In a 21 September 1989 memorandum, we addressed compliance of LLNL' s 8 June 1989 revised "Resource Conservation and Recovery Act (RCRA) Closure and Post-Closure Plans for Landfill Pits I and 7" (CP) with the California Code of Regulations, Title 23, Chapter 3, Subchapter 15 (Subchapter 15) . We found the CP did not consider Subchapter 15 siting criteria and construction standards nor did the CP offer an engineered alternative to these standards. The CP also did not quantitatively analyze the potential for ground water mounding beneath the inactive Pit 7, which could flood the landfill and release pollutants including lead, barium, beryllium, depleted uranium, tritium, and high explosives compounds to the ground water. The CP also did not comply with the Subchapter 15 requirement to install grout curtains, cutoff walls, or an engineered alternative to intercept lateral ground water flows beneath the landfills. To address these deficiencies, LLNL submitted a 17 November 1989 document entitled Response to Comments by the California Regional Water Quality Control Board on Closure and Post-Closure Plans (Volume II) for Landfi 11 Pits I and 7" (Subchapter 15 response). On 19 October 1989, the Department of Health Services issued a second Notice of CP Deficiencies (NOD) , to which the facility responded on 5 February 1990 with a revised CP. With the Subchapter 15 response, LLNL also submitted the "Remedial Investigation and Feasibility Study for the Pit 7 Complex" (RI/FS) . The RI/FS addresses remedial action to be undertaken at the inactive landfills Pits 3, 4, and 5, adjacent to Pit 7. The RI/FS will be reviewed separately and includes the hydrogeologic data and technical analyses LLNL used to develop the engineered alternatives presented in the Subchapter 15 response and the revised CP. The landfill closure specified in the Subchapter 15 response and in the revised CP must be consistent with each other and with Subchapter 15. Therefore, I reviewed both reports and, using the data presented in the RI/FS, I verified the hydrogeologic analyses leading to the proposed Subchapter 15 engineered alternatives. Discussion The Subchapter 15 response describes an engineered alternative to the following Subchapter 15 requirements: the Class I landfill siting criteria (Article 3) and construction standards (Article 4) , and the grout curtains or cutoff walls required under §2545.